SKN INDUSTRIES LTD POLICYON PRESERVATION OF DOCUMENTS AND ARCHIVAL POLICY

[Regulation 9 and 30(8) SEBI Listing Regulations, 2015]

1. TITLE

This policy shall be called “Preservation of Documents and Archival Policy’. In short it canalso be called as “PDAP".

2. OBJECTIVE

This policy is formulated in line with the requirement of Regulation 9 and Regulation 30(8) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (known as listing regulations) to prevent statutory records and documents as mentioned in various provisions of the Companies Act, SEBI (Prohibition of Insider Trading) Regulations, SEBI (Substantial Acquisition of Shares and Takeover) Regulations and such other acts, rules and regulation specially applicable to the company.

“Preservation" is the means by which documents I records are protected for the present or future use. The objective of preservation is to minimize the risk of loss of records and slowing down, as much as possible, the process of physical deterioration which affect most archive materials.

The documents specified in Annexure – 1 shall be preserved for the minimum period as mentioned in the annexure. However, company may keep those records for longer period in case there is a dispute pending before any court, department, judicial or quasi-judicial body etc.

3. APPLICABILITY

This policy shall be effective from ………………………………..

4. 4. COMMON STANDARDS FOR THE PRESERVATION OF RECORDS I DOCUMENTS

In order to preserverelevant documents effectively, the documents I records shall be:

    i. placed, handled, consulted and I or displayed in a way which minimize the risk of damage and takes due account of their size, shape and physical conditions;

    ii. Placed, handled, consulted and I or displayed in a safe and secure location;

    iii. Moved with due care between locations;

    iv. Placed, handled, consulted and I or displayed under appropriate preservation conditions such as avoid areas of unsuitable temperature and humidity or areas directly affected by ultra violet light.

    v. Proper account must be kept of the location of all the record.

    vi. Adequate infrastructure must be in place to preserve the records I documents and to avoid any serious damage or loss including the misuse, maltreatment or theft of records.

    vii. All departments, divisions or units involved and responsible for maintaining their records shall take appropriate measures for preventing records related to their areas and ensure that the adequate care be taken while taking charge from the person leaving the services of the company due to any reason.

5. RECORD STORAGE

    i. Sufficient space must be made available for the storage of records;

    ii. All permanent and temporary storage area must be safe and secure to minimize the risk of theft or malicious damage.

    iii. Storage area must be structurally sound and sufficiently strong to withstand adverse weather conditions;

    iv. Storage area should be fire proof and moisture proof;

    v. Storage area should be insect and rodent free.

    vi. Environmental conditions in permanent storage areas must be carefully controlled and regulated to reduce the threat of atmospheric contamination.

6. MECHANISM TO TAKE CARE OF RECORDS/ DOCUMENTS

    i. A full and accurate account of the precise location of all records should be maintained;

    ii. Checks and balances on the location of all records issued from or returned tostorage should be made;

    iii. Loss or theft of records should be noted I reported I investigated as deem necessary;

    iv. The physical conditions of records issued from or returned to the stores should be assessed and any physical change / damage should be noted /reported / investigated / treated as necessary.

7. MAINTAINING OF RECORDS /DOCUMENTS IN ELECTRONIC FORMS

In order to keep records / documents easily accessible at all the time at different locations, adequate steps to be taken tomaintain the records or documents in electronic form / scanned form and shall be kept withadequate indexation. The documents should be kept at the company server with passwordprotected under the supervision of Information Technology Department.

8. CONSERVATION AND REPAIR OF RECORDS I DOCUMENTS

The conservation treatments of relevant records / documents should be done in such a manner so that life span of the documents / records shall be improved.

9. Copying or reformatting of Records

In order to preserve original documents for longerperiod, exposure to the physical dangers of actual loss or damage through excessive handlingneed to be minimized. Hence, it is necessary that critical documents should be kept inscanned form duly authenticated by the members of the Board or company secretary or thehead of the respective department and the same to be referred or provided whenevernecessary. It is also to be ensured that copies should not be confused with the originals hence,every copied or reformatted documents must contain the seal of the company stating that thisis not an original document.

10. AMENDMENTS

Any subsequent amendment / modification in the listing regulations and / or other applicablelaws in this regard shall automatically apply to this Policy.
The Board of directors shall periodically review the policy keeping in view the amendmenttaken place in various laws applicable to the company and accordingly update this policy.

Annexure